The EU Packaging and Packaging Waste Regulation (PPWR) represents a significant shift in packaging sustainability requirements across all Member States. Replacing the Packaging Directive (94/62/EC), it establishes stricter rules on recyclability, waste prevention, and reuse.
For businesses that produce or use packaging, understanding these new obligations is crucial for compliance and maintaining market access in the EU.
This guide is divided into two key sections:
- Obligations for Packaging Producers – detailing the specific requirements companies must follow.
- Key Regulations and Guidance – providing an overview of the legislative framework, enforcement, and compliance steps.
Obligations for Packaging Producers
Under the PPWR, packaging producers must adhere to stricter sustainability measures aimed at minimising environmental impact. These obligations include:
1. Ensure Packaging is Recyclable at Scale
- By 2030, all packaging must be designed for recycling according to defined criteria.
- By 2035, packaging must be both recyclable and effectively recycled at scale, meaning 30% for wood and at least 55% of all other packaging categories is successfully recycled EU-wide.
2. Use Minimum Levels of Recycled Content in Plastic Packaging
Producers must incorporate minimum levels of post-consumer recycled (PCR) content in plastic packaging:
- 10% by 2030 for food-contact-sensitive plastics (25% by 2040).
- 35% by 2030 for all other plastic packaging (65% by 2040).
- 30% by 2030 for PET beverage bottles (65% by 2040).
- Applies to plastic components constituting 5% or more of total packaging weight.
3. Reduce Packaging Waste & Optimise Packaging Design
- Packaging weight and volume must be minimised while ensuring functionality.
- Ban on certain single-use plastic packaging types from 2030 (e.g., for very lightweight fresh produce, hotel toiletry bottles).
- E-commerce packaging must not exceed 50% empty space to prevent wasteful over-packaging.
4. Implement Reuse and Refill Solutions
- Certain industries (beverage, e-commerce, hospitality) must increase the share of reusable packaging.
- Develop and manage reuse and refill systems designed for packaging collection and reusability.
5. Comply with Harmonised Labelling Requirements
- Standardised labels on all packaging to indicate:
- Material composition for recyclability.
- Disposal instructions for consumers.
- QR codes or digital links must provide additional recycling information.
- Labels must be consistent across all EU countries.
6. Extended Producer Responsibility (EPR) & Eco-Modulated Fees
- Companies must finance and participate in national EPR schemes.
- EPR fees are eco-modulated, meaning:
- Easier-to-recycle packaging pays lower fees.
- Non-recyclable or hard-to-recycle packaging incurs higher fees.
- Producers must submit detailed data to demonstrate compliance.
7. Demonstrate Compliance Through Conformity Assessments
- From 2030, companies must prove compliance with design, recyclability, and waste prevention rules.
- Compliance documentation must be available for authorities upon request.
8. Eliminate Certain Hazardous Substances in Packaging
Packaging must be free from harmful substances, including per- and polyfluoroalkyl substances (PFAS) and other restricted chemicals.
Understanding PPWR: Key Regulations and Guidance
What is the EU Packaging and Packaging Waste Regulation (PPWR)?
The Packaging and Packaging Waste Regulation (PPWR) is a new EU legislative framework that will replace the existing Packaging and Packaging Waste Directive (94/62/EC).
It introduces consistent rules across the European Union covering packaging design, recyclability, labelling, reuse requirements, and data reporting. The objective is to reduce packaging waste and support the transition to a more circular packaging economy across Member States.
What are the key objectives of PPWR?
- Reduce packaging waste by 15% per capita by 2040.
- Ensure all packaging meets EU recycling requirements by 2030.
- Increase reuse and refill systems across key sectors.
- Introduce harmonised labelling to improve consumer recycling habits.
When will the PPWR take effect?
The PPWR formally entered into force on 11 February 2025 and will start to apply from 12 August 2026.
Implementation will be phased, with additional technical requirements introduced gradually between 2026 and 2030 through delegated and implementing acts that define detailed compliance rules.
Who does PPWR apply to?
The Packaging and Packaging Waste Regulation (PPWR) applies to any organisation placing packaging or packaged products on the EU market.
This includes:
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Manufacturers
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Importers
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Distributors
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Brand owners
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Online retailers and marketplace operators
The regulation applies to all packaging materials, not just plastics, and covers both B2B and B2C packaging.
UK businesses exporting packaged goods into the EU must also comply with PPWR requirements when placing those products on the EU market.
How does PPWR differ from the previous Packaging Directive?
The earlier Packaging and Packaging Waste Directive required EU Member States to transpose its provisions into national law, which led to differences in implementation between countries.
By contrast, the PPWR is a directly applicable EU Regulation, meaning the same rules will apply across all Member States without national transposition.
The regulation introduces several new elements, including:
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Harmonised packaging labelling requirements
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Mandatory recyclability criteria for packaging
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Reuse and reduction targets
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More standardised digital reporting requirements
What are the key PPWR compliance deadlines?
Important dates for businesses to be aware of include:
What labelling changes will PPWR introduce?
PPWR introduces harmonised waste sorting labels that must appear on packaging across the EU.
These labels are intended to provide clear instructions to consumers on how packaging should be disposed of, helping to improve sorting accuracy and recycling rates.
What are the Material-Specific Regulations?
- Glass, paper, metals, wood, and plastics must meet specific recycling targets.
- Recyclability assessment methodology will be fully implemented by 2028.
- Recyclability must be assessed per packaging unit rather than by weight.
How does PPWR affect online marketplaces?
Under the regulation, online marketplaces will have greater responsibility for ensuring that sellers using their platforms comply with packaging requirements.
This change extends regulatory accountability across the digital supply chain and aims to prevent non-compliant products entering the EU market through third-party sellers.
What documentation is required under PPWR?
Manufacturers of packaging will be required to complete a conformity assessment procedure.
This involves preparing technical documentation demonstrating that packaging meets the relevant PPWR sustainability requirements.
Businesses placing packaged products on the market must ensure that this documentation exists and is available if requested by regulators.
In practice:
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Manufacturers demonstrate compliance, and
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Producers verify that compliant documentation is in place.
What is a Declaration of Conformity?
A Declaration of Conformity (DoC) is a formal document confirming that packaging complies with the applicable requirements under the PPWR.
It forms part of the conformity assessment process and must be issued by the packaging manufacturer.
Each declaration should include:
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A unique reference identifying the packaging
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The manufacturer’s name and contact details
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A statement confirming compliance with relevant PPWR provisions
The declaration must be available for packaging placed on the market in the EU and Northern Ireland.
How can I stay informed about PPWR developments?
The PPWR framework will continue to evolve as the European Commission publishes additional delegated and implementing acts, providing further detail on how specific requirements must be applied in practice.
Clarity will support businesses in keeping pace with these developments. We provide regular regulatory updates, expert analysis, and practical guidance as new PPWR requirements emerge. This includes webinars, technical briefings, and insight articles that explain what the changes mean for packaging producers and how they may affect packaging design, data management, and compliance obligations.
Our aim is to help businesses understand upcoming requirements early, giving them the clarity and confidence to prepare for future deadlines and adapt their packaging strategies as the regulation develops.
Sources & Further Reading
- Official Journal of the EU: Final PPWR Text
- Green Business: New EU regulation promotes the procurement of sustainable packaging – European Commission
- European Chemicals Agency: Understanding the Packaging and Packaging Waste Regulation – ECHA
Summary & Next Steps for Packaging Producers
The PPWR sets out a clear roadmap for sustainability in packaging, placing increased responsibility on producers to:
- Design packaging for recyclability with strict targets.
- Reduce packaging waste through minimisation and reuse schemes.
- Meet mandatory recycled content requirements for plastic packaging.
- Comply with extended producer responsibility (EPR) obligations.
- Ensure all packaging is appropriately labelled and documented.
As enforcement begins, businesses must proactively assess their packaging portfolios, work towards recyclability goals, and prepare for future regulatory deadlines to maintain market access and compliance.
Reach out to our compliance experts
If you would like to discuss how PPWR may affect your business, you can schedule a short 15-minute guidance session with one of Clarity’s PPWR experts, to explore the key considerations and next steps.
Simply complete the form below and we’ll be in touch.
